Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 1 of 21
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
UNITED STATES OF AMERICA
RYAN ANDREW GUSTAFSON
a/k/a/ Jack Farrel
a/k/a/ Willy Clock
AFFIDAVIT IN SUPPORT OF COMPLAINT
I, Special Agent Keith E. Heckman, being first duly sworn, hereby depose and state as
INTRODUCTION AND AGENT BACKGROUND
1. I am a Special Agent with the United States Secret Service ("USSS"). In this
capacity, I am responsible for investigating possible violations of federal criminal law, including
the manufacturing and distribution of counterfeit Federal Reserve Notes ("FRNs") in violation of
18 U.S.C. §§ 371 (conspiracy), 470 (counterfeit acts committed outside the United States), 471
(manufacturing of counterfeit obligations), 472 (uttering counterfeit obligations), 473 (dealing in
counterfeit obligations), and 1029 (access device fraud).
2. I have been employed as a Special Agent with the Secret Service since July 08,
1996, and I am currently assigned to the Pittsburgh Field Office. I primarily investigate financial
fraud and counterfeiting crimes. By virtue of my USSS employment, I have gained experience
in conducting such investigations, in drafting and execufing search and arrest warrants relating to
manufacturing and distribution of counterfeited U.S. currency, and in the collection of
computer-related evidence. I also have received extensive training in general law enforcement
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 2 of 21
and criminal investigations, including the manufacturing and distribution of counterfeit United
States currency, access devices, and identity theft violations at the Federal Law Enforcement
Training Center, in Glynco, Georgia and at the James J. Rowley Training Center in Behsville,
3. By virtue of my USSS employment, I perform and have performed a variety of
investigative tasks, including functioning as a case agent on counterfeiting cases. I have received
extensive training in general law enforcement and criminal investigations, including the
manufacturing and distribution of counterfeit United States currency, access devices, and identity
theft violations at the Federal Law Enforcement Training Center, in Glynco, Georgia and at the
James J. Rowley Training Center in Beltsville, Maryland. Moreover, I have gained experience in
conducting such investigations and in executing search and seizure warrants.
4. As a federal agent, I am authorized to investigate violations of laws of the United
States and am a law enforcement officer with the authority to execute warrants issued under the
authority of the United States.
5. The information contained in this affidavit is based upon my personal knowledge,
knowledge obtained during my participation in this investigation, knowledge obtained from other
individuals including other law enforcement personnel and witnesses, knowledge obtained from
my review of documents, electronic records, counterfeit Federal Reserve Notes, and other
evidence related to this investigation, and knowledge gained through my training and experience.
All conversations and statements described in this affidavit are related in substance and in part
unless otherwise indicated. Because this affidavit is being submitted for the limited purpose of
establishing probable cause, I have not included every detail of every aspect of the investigation.
Rather, I have set forth only those facts that I believe are necessary to establish probable cause.
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 3 of 21
6. This Affidavit is in support of an application for a criminal complaint against and
an arrest warrant for RYAN ANDREW GUSTAFSON, also known as "Jack Farrel" and "Willy
Clock." As set forth herein, there exists probable cause to believe that RYAN ANDREW
GUSTAFSON and others have violated Title 18, United States Code, Sections 371 (Conspiracy)
and 470 (Counterfeiting Acts Committed Outside the United States).
7. This affidavit establishes probable cause to believe that GUSTAFSON and others
are participating in a conspiracy to manufacture, deal in, possess, and pass counterfeit Federal
Reserve Notes that are believe^ to be manufactured in Uganda.
8. This affidavit also establishes probable cause to believe that GUSTAFSON
manufactured counterfeit Federal Reserve Notes in Uganda and sold and exchanged counterfeit
Federal Reserve Notes in Uganda.
9. At all times material to this affidavit, RYAN ANDREW GUSTAFSON was a
citizen of the United States and an adult individual who was bom in August of 1 987. He uses the
nicknames "Willy Clock" and "Jack Farrel," and he currently lives in Kampala, Uganda.
1 0. At all times material to this affidavit, J.G. lived in the Western District of
B. Counterfeit Federal Reserve Notes in Western District of Pennsylvania
11. Starting in December 2013, the United States Secret Service (USSS) began
investigating the passing of counterfeit Federal Reserve Notes (FRNs) believed to be
manufactured in Uganda at retail stores and businesses in the Western District of Pennsylvania.
As a result of this investigation, the USSS collected the counterfeit FRNs that were passed.
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 4 of 21
These notes, based on analysis, matched the make and identifiers of notes known to be
manufactured in Uganda; the USSS, therefore, beheves that these counterfeit FRNs were
manufactured in Uganda.
12. In addition, USSS collected surveillance videos, witness statements, and
sale/return receipts concerning the passing of these counterfeit FRNs.
13. On December 26, 2013, a counterfeit $100 FRNs was passed at Feet's Coffee in
the Oakland neighborhood in Pittsburgh, Pennsylvania. Receipts show that an individual bought
a coffee with a counterfeit $100 FRN and received $96.15 in genuine U.S. currency in change.
Video surveillance captured an individual, later identified as J.G., passing the counterfeit $100
FRN to effectuate this transaction.
14. Also, on December 26, 2013, counterfeit $100 FRNs were passed in two
transactions at Rite-Aid in the Oakland neighborhood in Pittsburgh, Pennsylvania. First, the
individual made a small item purchase with a single counterfeit $100.00 FRN and received $80
genuine U.S. currency. Second, this individual used sixteen (16) $100.00 counterfeit FRNs to
wire transfer $1,500 via Western Union. Records from Western Union confirmed that this
$1,500 wire transfer was sent to an individual in Uganda. USSS obtained video surveillance
from Rite-Aid of these transactions, which depicts J.G. passing the counterfeit $100 FRNs.
15. On January 25, 2014, counterfeit $50 FRNs were passed at CVS in Carnegie,
Pennsylvania. Video surveillance showed J.G. passing nine (9) counterfeit $50.00 FRNs to
purchase a prepaid debit/credit card.
16. On January 29, 2014, counterfeit $20 FRNs were passed at Walgreens in
McCandless Township, Pennsylvania. Twenty-five counterfeit $20 FRNs were used to purchase
a PayPal card. Based on my training, knowledge, and experience, your Affiant knows that
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 5 of 21
PayPal cards operate similarly to credits cards. USSS obtained video surveillance of this
transaction, which showed J.G. passing the counterfeit FRNs.
17. Law enforcement was able to identify the individual in these surveillance videos
as J.G. because J.G. was recently placed on pretrial supervision for an unrelated criminal case
pending before the United States District Court in the Western District of Pennsylvania. USSS
reviewed the surveillance videos and was able to identify the individual on the video as J.G.
18. In each of the transactions described above, USSS recovered the counterfeit FRNs
passed by J.G. Special Agent Timothy Spiess reviewed the recovered FRNs and was able to
determine that they were not genuine United States currency.
19. In addition, USSS compared the identifiers found on the suspect notes with
known samples of counterfeit notes produced in Uganda. USSS analysis confirmed that these
counterfeit FRNs matched the identifying features of counterfeit notes that are known to have
originated from Uganda.
20. As part of J.G.'s unrelated criminal case, the FBI was aware that J.G. rented the
postal box 395 at The UPS Store at 1739 East Carson Street, Pittsburgh, PA 15203. On or about
February 19, 2014, law enforcement learned that J.G. received three DHL packages from
Uganda to this UPS Store Box 395. These packages were addressed from Beyond Computers,
Titanic Plaza Wilson Road, PO Box 37644, Shop TD 1 1, Kampala, Uganda. The packages also
contained the specific name of the individual who shipped the packages. This person will be
referred herein as A.B.
21. On February 21, 2014, law enforcement obtained a search and seizure warrant to
open these three DHL packages as well as other mail items for evidence of counterfeiting
currency. United States Secret Service Special Agent Timothy Spiess executed this search
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 6 of 21
warrant; contained inside these DHL packages were either a blank white paper or a document
that purported to be a general partnership agreement. However, Special Agent Spiess found
counterfeit FRNs that were located in two hidden compartments within a secondary package
inside the shipping envelope. The USSS has reviewed all the bills found in these three packages
and was able to determine that all the bills were not genuine U.S. currency. In total, USSS found
counterfeit $100, $50, and $20 FRNs totaling approximately $7,000 inside these three DHL
packages. The USSS matched the identifying features of the approximate $7,000 in counterfeit
FRNs with those that are known to have originated from Uganda.
22. The packages, the blank white papers, the general partnership agreements, and a
few representative counterfeit bills were submitted for fingerprint analysis. This analysis
resulted in a positive identification; the forensic laboratory was able to find a fingerprint on the
general partnership agreement that belonged to RYAN ANDREW GUSTAFSON.
23. Additionally, USSS requested assistance from United States Customs and Border
Protection ("CBP") to identify recent DHL packages coming from Kampala, Uganda to the
United States that were associated with A.B. As a result, law enforcement officials were
successful in seizing numerous packages containing counterfeit FRNs.
C, Shipments of Counterfeit Federal Reserve Notes from Uganda
24. The Secret Service worked with Ugandan authorities to identify the source of
these counterfeit Federal Reserve Notes. This investigation focused on A.B., the person who
sent the packages to J.G. Ugandan authorities, with assistance from Secret Service, arrested and
interviewed A.B. A.B. admitted to sending the packages containing counterfeit U.S. currency to
the United States. He explained that an American, who used the name Jack Farrel, and another
individual known as Lumu Jumah provided him the counterfeit Federal Reserve Notes to ship.
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 7 of 21
25. Your Affiant is aware that Facebook owns and operates a free-access social
networking website of the same name that can be accessed at http://www.facebook.com.
Facebook allows its users to establish accounts with Facebook, and users can then use their
accounts to share photographs, videos, written news, personal information, and other information
with other Facebook users and sometimes with the general public.
26. Secret Service searched Facebook for the name Jack Farrel and discovered a
Facebook user site for an individual named Jack Farrel who claimed to live in Uganda. This
user's Facebook site also had photographs of Jack Farrel.
27. A.B. was shown one of the photographs from Jack Farrel's Facebook site. A.B.
confirmed that this photograph was the Jack Farrel who provided him with the counterfeit
Federal Reserve Notes.
28. Facial recognition analysis matched Jack Farrel's photograph with a Texas
Department of Motor Vehicle photo of RYAN ANDREW GUSTAFSON.
29. Ugandan authorities are prosecuting A.B. for his role in this counterfeiting
D. J.G/s Communications with Willy Clock
30. Law enforcement agents interviewed J.G. concerning the counterfeit Federal
Reserve Notes. J.G. explained that he met Willy Clock on an online criminal forum/marketplace
called Tor Carding Forum ("TCF"). J.G. accessed the internet in Pittsburgh, Pennsylvania.
Through private messaging on the TCF, J.G. and Willy Clock discussed counterfeit currency
including printing methods and craft trade concerns. J.G. agreed to purchase $4,000.00 in
counterfeit U.S. Federal Reserve Notes and Willy Clock instructed J.G. to wire the money
through Western Union to Lumu Jumah in Uganda. On December 18, 2013, J.G. sent $1,500 in
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 8 of 21
genuine U.S. currency through Western Union to Lumu Jumah. Willy Clock sent the counterfeit
Federal Reserve Notes in two separate shipments to J.G. in the Western District of Pennsylvania.
Each shipment contained $2,000 in counterfeit $100 Federal Reserve Notes.
3 1 . J.G. made subsequent purchases of counterfeit Federal Reserve Notes from Willy
Clock. J.G. also communicated with Willy Clock through Willy Clock's jabber* account
32. Sometime in January 2014, Willy Clock informed J.G. that he set up his own
online forum called Community-X, which was a TOR website dedicated to the selling of
counterfeit Federal Reserve Notes. J.G, was invited to join Community-X. Community-X is an
online forum that requires a usemame and password to access, and individuals must be invited
and approved by Willy Clock in order to become members of the site. Members can
communicate to each other openly on a community message board or can communicate with
selected members through private messaging. On the Community-X forum, Willy Clock
discusses his counterfeit notes and members talked to each other about the passing of counterfeit
Jabber communication is essentially a near real-time instant messaging service. Jabber
generally requires a central server to coordinate ingoing and outgoing messages. The messages
are sent to and from account holders whose account address appear similar to e-mail addresses;
for firstname.lastname@example.org would be the Jabber address for the unique jabber
account of johndoe andjabberserver.com is the Jabber server. Usually, Jabber messages are not
retained by the sender or the receiver unless those account holders manually choose to log or
record their conversations.
TOR, also known as 'The Onion Router," is free software that uses a network of computers
that allows computer users to access the Internet anonymously. TOR directs the users Internet
traffic through this computer network such that users' IP addresses are hidden. The IP address
used to access a website is, essentially, a random IP address of a TOR computer. In addition,
there are certain websites that can only be accessed through the use of TOR. These websites
contain a .onion domain name, and their location (i.e., the IP addresses hosting these websites)
also are hidden. Community X is a TOR website that has a .onion domain name.
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 9 of 21
33. In addition, through Community-X, Willy Clock offered an instructional guide
that discussed how to successfully pass counterfeit Federal Reserve Notes without getting
detected. Willy Clock sent J,G. a copy of this guide.
34. After being arrested by Secret Service in February 2014, J.G. was banned from
Community-X by Willy Clock.
E, Undercover Communications with Willy Clock
35. USSS obtained access to a Confidential Informant's Community-X account. This
undercover operative (referred herein as "CI-l") began communicating with Willy Clock around
April 30, 2014. In addition to Community-X, Willy Clock provided CI-1 with a number of ways
to contact him, including the email accounts willv.clock@yandexxom , the ICQ (instant
messaging) account number 661656905, the jabber (instant messaging) accounts
email@example.com and firstname.lastname@example.org.
36. Through these accounts, CI-1 arranged the purchase of $5000.00 counterfeit $50
and $100 FRNs on or about April 30, 2014 and May 1, 2014. Based on Willy Clock's
instructions, CI-1 wired genuine U.S. currency to a fake name that Willy Clock provided.
37. On May 20, 2014, Willy Clock sent two emails to CI-1 from his
email@example.com . In the first email, Willy Clock apologized that the shipment to CI-1
was taking so long and promised to send the tracking number of the package. In the second
email, Willy Clock sent the tracking number. The first email was sent at 20:30:39 UTC and the
second email was sent at 21 :42:04 UTC. Both emails were sent from the IP address
126.96.36.199, which resolves to an Internet Service Provider in Great Britain.
38. During this investigation, the Secret Service learned that there were a number of
Facebook accounts under the name of Jack Farrel and Ryan Gustafson that appear to be used
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 10 of 21
and/or controlled RYAN ANDREW GUSTAFSON. For instance, the Jack Farrel 94 account is
associated with the same email address that Gustafson provided on his U.S. passport application.
In addition, on a number of occasions, this account was accessed with the same IP address on the
same date around the same time that, another account, the El Jack Farrel account was accessed.
Based on my knowledge, training, and experience, the use of the same IP at the same date and
time frequently indicates that the same individual accessed both accounts. In addition, the Ryan
Gustafson 39 account is associated with the email address iackfarrel@livexom .
39. According to records from Facebook, an individual logged into the El Jack Farrel
account on May 20, 2014 at 10:26:52 UTC with the IP Address 79.143,82.250, which is the
same IP address and the same date that Willy Clock sent the two emails to the CM . Although
the El Jack Farrel account was logged into from the IP address 50.23.1 15.125 on May 20, 2014
at 19:10:12 UTC and 19:10:27 UTC, there was no corresponding logout from the 188.8.131.52
IP address. Thus, it is possible that the later log ins may have been from different computers.
Nevertheless, the same Great Britain IP address accessed the El Jack Farrel Facebook account
and sent the email to CI-1 on the same day.
40. On May 23, 2014, a United States Postal Service (USPS) Priority Mail parcel was
delivered to CI-l's undercover address. The USPS tracking number for this package was the
same number that Willy Clock provided in his May 20, 2014 email. A review of the contents of
the shipment revealed the package contained fifty-two (52) counterfeit $100 FRNs. USSS
analyzed these 52 bills and determined that the bills were not genuine U.S. currency. In
^ This suggests that RYAN ANDREW GUSTAFSON has more than one electronic device that is
capable of accessing the Internet.
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 11 of 21
addition, the bills matched the make and identifiers of notes known to be manufactured in
41. Based on discussions between CI-1 and Willy Clock, CI-1 learned that Willy
Clock was using U.S. -based re-shippers to ship packages of counterfeit Federal Reserve notes
within the United States. The May 23 package was sent through a re-shipper. A re-shipper is an
individual, who is recruited by another to accept shipments on the sender's behalf and then
forward onto others as a means of maintaining anonymity of the sender. This process injects
layers into the shipping process and can be used to mask the identity of the sender, the recipient,
42. The CI-1 entered discussions with Willy Clock to be a re-shipper of counterfeit
Federal Reserve notes. Willy Clock agreed to give the CI-1 an opportunity to be a re-shipper.
Willy Clock informed CI-1 that the counterfeit currency must be treated by the re-shipper.
43. On or about September 17, 2014, Willy Clock created a sub-thread on
Community-X called ''AnonHands UPDATE!" that was located within the thread
AnonymousHands. Based on the pictures and description provided by Willy Clock on the sub-
thread, "Anon Hands" are rubber molds of Willy Clock's hands that have the appearance and
color of a real hand. They fit like gloves over his real hands and are meant to conceal his
fingerprints. In the thread, Willy Clock indicated that he had "Anon Hands" made for himself
44. Although CI-1 eventually became a re-shipper, he was a low level re-shipper and
always received packages from other U.S.-based re-shippers. CI-1 received a number of other
Willy Clock packages. For instance, through Willy Clock, a U.S.-based re-shipper sent a United
States Postal Service (USPS) Priority Mail parcel to CI-1 . This parcel was delivered to CI-l's
undercover address on or about October 7, 2014. A review of the contents of the package
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 12 of 21
revealed the package contained $3,000.00 in counterfeit $100 Federal Reserve notes. In fact, the
USSS analyzed the $3,000 in counterfeit FRNs and was able to determine that they were not
genuine United States currency. In addition, the USSS matched the identifying features of these
counterfeit notes with those that have originated from Uganda.
45. In early November 2014, USSS executed a search warrant upon the residence of
one of the re-shippers. This re-shipper became a Confidential Informant (''CI-2") for the USSS.
CI-2 had been an active member of Community-X since January 2014.
46. CI-2 explained that Willy Clock changed his distribution operation after USSS
seized his DHL packages and after A.B. was arrested. According to CI-2, around July 2014, a
Community-X member traveled to Uganda and brought back over $300,000 in counterfeit FRNs.
47. Due to the volume of counterfeit notes, CI-2 was recruited to assist in unpacking
the counterfeit FRNs and shipping it to the re-shippers. The counterfeit FRNs were within glued
together pages of ''save the children" pamphlets. The process of unpacking required placing
pamphlets in hot water until the glue dissolved.
48. CI-2 explained the treatment process, which was similar to the treatment process
that Willy Clock had instructed CI-1. The process involved using a heat press and hairspray so
that the counterfeit notes could bypass detection pens and look more genuine.
49. On or about November 17, 2014, Willy Clock made a posting stating that
approximately $250,000 in counterfeit FRNs had "just arrived in the United States."
F. Search and Arrest of RYAN ANDREW GUSTAFSON
50. The Secret Service, working with Ugandan authorities, engaged confidential
informants in Uganda who had knowledge of Jack Farrel and his counterfeit FRNs operation.
On or about December 11, 2014, one of the Ugandan confidential informants C'CI-3") called
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 13 of 21
Jack Farrel to make a buy of counterfeit FRNs. CI-3 agreed to buy $10,000 of counterfeit FRNs
from Jack Farrel for approximately 5.5 million Ugandan Shillings (which is approximately
$2000 in genuine U.S. currency).
5 1 . That same day, CI-3 met Jack Farrel 's houseboy, Kojo Christopher, and
conducted the buy. Cl-3 received $10,000 in counterfeit FRNs, and Kojo Christopher received
the genuine U.S. currency. Two trusted sources independently followed Kojo Christopher back
to Jack Farrel's house. The trusted sources reported the location to the USSS, which provided
the information to Dennis Owau, a detective inspector with the Uganda Special Investigation
52. That same day, Detective Owau led a search of Jack Parrel's residence. Upon
entering the residence, both RYAN ANDREW GUSTAFSON a/k/a Jack Farrel and Kojo
Christopher were arrested.
53. The Ugandan authorities recovered the following relevant items from the search:
2 million Ugandan Shillings that can be traced to the buy with CI-3, "Give a Child Hope Today"
Pamphlets with counterfeit FRNs in between glued together pages, at least 2 pages of uncut
sheets of counterfeit FRNs, a pair of Anon hands (which looked identical to the images posted on
Community-X), a $10,000 money wrapper with the signature of Willy Clock, $180,420 in
counterfeit FRNs with identifiers and features similar to the other known counterfeit FRNs from
Uganda, €13,600 in counterfeit Euros, 2,500 in counterfeit Indian Rupees, 1,500 in counterfeit
Ugandan Shillings, 400 in counterfeit Congo Franc, 38 in counterfeit Ghana Cedi, peel off
stickers of Euro security features that are found on Euros, 2 desktop computers, 2 laptop
computers, approximately 10 USB thumb drives, approximately 3 routers, a number of cellular
telephones, a number of printers, approximately 2 paper cutters, approximately 1 scanner, ink in
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 14 of 21
bottle, ink in cans, inkjet cartridges, counterfeit detection pens, approximately 200 glue sticks,
receipt for the purchase of printer parts from Hong Kong, Western Union and Moneygram
receipts, box of blank white plastic cards that are used to create credit cards, a photocopy of
RYAN ANDREW GUSTAFSON's passport, RYAN ANDREW GUSTAFSON's Texas
Identification Card, RYAN ANDREW GUSTAFSON's Colorado driver's license, an official
Kenyan document charging RYAN ANDREW GUSTAFSON with unlawful possession of a
firearm, and approximately 2 Taser guns.
54. Some photos of the evidence seized are provided in Attachment B, which is
attached hereto and incorporated herein by reference.
55. USSS recovered the $10,000 in counterfeit FRNs that Kojo Christopher provided
CI-3. USSS reviewed these bills and has determined that they are not genuine U.S. currency. In
addition, these bills match the same identifiers and features of known Ugandan made counterfeit
FRNs and the same identifiers and feature of the counterfeit FRNs passed by J.G.
56. USSS placed this $10,000 in counterfeit FRNs in a USSS evidence envelope and
provided it to Detective Owau to be placed in evidence with the items seized from RYAN
ANDREW GUSTAFSON's residence.
G. Summary of Counterfeit
57. USSS typically learns about the passing of counterfeit FRNs overseas through
criminal cases brought by local governments and by seized counterfeit FRNs that are sent to U.S.
Embassies overseas. Based on known criminal cases and counterfeit FRNs sent to the U.S.
Embassy in Kampala, USSS can confirm that approximately $1.8 million in counterfeh FRNs
have been passed in Uganda.
58. The total amount of counterfeit FRNs manufactured in Uganda that has been
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 15 of 21
seized or passed within the United States is approximately $270,000.00. However, as mentioned
earlier, CI-2 has learned from Willy Clock that Willy Clock has moved approximately $5,500.00
of counterfeit FRNs into the United States since July 2014.
59. Based on the above information, your Affiant believes that probable cause exists
that RYAN ANDREW GUSTAFSON violated Title 18, United States Code, Sections 371
(Conspiracy) and 470 (counterfeit acts committed outside the United States) and prays that a
warrant be issued for his arrest.
The above information is true and correct to the best of my knowledge, information, and
^eith E. Heckman
Special Agent, United States Secret Service
Subscribed and sworn to before me
this \7^^ day of December, 2014
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 16 of 21
Case 2:14-mj-01168-LPL Document 1-1 Filed 12/17/14 Page 20 of 21